CLECAT Position Paper on the Proposal for a Regulation on Electronic Freight Transport Information (eFTI)

The European Commission published
a proposal
for a Regulation on electronic Freight transport information (eFTI)
on 17 May 2018 as part of the third Mobility Package. Through this proposal the
Commission wants to establish a fully digital environment for information
exchange in freight transport, replacing paper transport documents, which will
facilitate digital information flows for logistic operations.

CLECAT, the European Association
of Freight Forwarders, Logistics service providers and Customs Agents, welcomes
the proposal which sets an important basis for the establishment of a 100%
digital environment for information exchange in transport, to the benefit of
both the business community and the authorities. Despite the fact that it is
expected that implementation will lead to substantial implementation costs, the
alternative (no EU Regulation) would mean that the national or local
authorities will continue with the development of their individual
digitalisation initiatives, without any further coordination or harmonisation
efforts. The result would be an even more fragmented transport environment and
much higher implementation costs for businesses. In the long run, an EU
Regulation addressing the legal acceptance by authorities of digital data is
therefore seen as crucial by CLECAT and its Members.

Nonetheless, CLECAT considers it
very important that harmonisation should not be introduced by replacing already
existing and properly functioning IT systems, but by re-using the existing
solutions and focusing on how to make these solutions more interoperable
through data harmonisation and the way these systems exchange data. While
establishing data sets and other requirements in legislation, CLECAT considers
it also important that already existing standards are being considered. Having
said this, CLECAT considers that some parts of the proposal require more
fine-tuning. If this is not addressed within the Regulation itself, it could
potentially lead to unintended and unnecessary burdens.

CLECAT also calls for a more
detailed work programme with more tangible and clearly defined goals to achieve
digitalisation, harmonisation and especially less burdens. The foreseen
implementation costs for both the public (EUR 268 million) and the private
sector (EUR 4.4 billion) are very high. Without a more detailed work programme
and a clear common vision of what the desired end state will be, the risk of
wasting the foreseen investment is too high.

CLECAT has been an active
participant of the DTLF and has supported and contributed to other Commission
initiatives in the field of digital transport and logistics and will continue
to do so. The efforts of the Commission are highly appreciated. Therefore,
CLECAT looks forward to a constructive dialogue with the European Parliament
and Member States, so work on an actual digital transport environment can
commence and the intended benefits can be achieved for all stakeholders
involved.